One looming question: will the ban work? Some mom and pop shop owners are so desperate for sales in the recession that they've turned to offering dirt-cheap but illegal rat poisons, often from China. On Sept. 19, 12 people were arrested in New York City's Chinatown for selling brodifacoum and sodium fluoroacetate-laced products which, because they look like cookies, could attract children, Manhattan District Attorney Cyrus Vance said at a news conference. The U.S. has forbidden use of sodium fluoroacetate against rats since 1972.

And while commending the EPA "for trying to reduce the risk of poisoning," DeClementi says that although the new regulations would stop most cats from being poisoned, many dogs will simply chew open the poison-strewn blocks, called "bait stations," that will be required if the regulations take effect. "Dogs," she says, "explore the world with their mouths. The same thing that makes the bait attractive to rodents will make it attractive to dogs. Dogs will seek the stations out."

Worse yet, DeClementi, a veterinarian who's been with the ASPCA since 1999, predicts that the ban will produce an unintended consequence: if they lose in court, pest control companies will switch to selling a class of other, even more deadly poisons known as "first generation" rodenticides.

And their two most likely choices, believes DeClementi, will be bromethalin, a neurotoxin which causes paralysis or seizures that are almost impossible to treat, and cholecalciferol, a form of vitamin D which, in high doses, induces kidney failure that requires lengthy and expensive treatment.

"I wonder if sterlizing rodents would work better?" she asks. "But would eating rats on birth control also kill birds of prey?"

For now, she favors products that catch rodents "in a little house," such as rat zappers, and telling bird lovers to "keep their bird seed in containers instead of bags."

Others favor more natural approaches. After rats seeking warm places to nest caused a reported $5,000<\d>$7,000 in damage to vehicles by chewing their carpets and other parts in the garage of the Marin County Civic Center, the county, in cooperation with the Hungry Owl Project, spent less than $1,000 to put up six barn owl boxes adjacent to the San Rafael building September 10. Each owl family can consume up to 5,000 of the voracious vermin per year.

Meanwhile, not everyone is waiting for the EPA's rules to go into effect. Retailers around the USA are starting to withdraw rat pellet bait products.

Now that the EPA has published its rule change, stores in New York must, under state law, take the rat bait products off their shelves. And after the discovery of four dead Cooper's hawks, three of which tested positive for rodenticide poisoning, activists in California say they will press for the enactment of a similar law.

"I'm outraged at the makers of these rodenticides for not caring about people or the welfare of animals," says Lisa Owens Viani, who founded Raptors Are The Solution (RATS) this summer after a Cooper's hawk was found dead on a sidewalk off Berkeley's Bancroft Street, four years after three other Cooper's hawks died in her Berkeley neighborhood. Tests by the University of California at Davis showed the sidewalk hawk had ingested the rodenticides brodifacoum and diphacinone; two of the other birds tested positive for brodifacoum.

"The companies that are fighting (the EPA) are some of the same ones that make rodent traps," she says. "They will still have plenty of other products to sell."

Owens Viani, who led a jam-packed organizing meeting of RATS August 26, says part of her motivation to act is "a personal thing. I have lots of animals.